PRIVACY AND DATA POLICY

ISSUED BY UNIT 2 GAMES LIMITED (“UNIT 2”, or “we” or “us”).

Last updated 18 September 2018

1. INTRODUCTION AND GENERAL TERMS

These terms apply to the use of CRAYTA, developed by Unit 2 Games Limited (“Unit 2 Games” / “we” / “us”). Our registered office is at 2 Jephson Court, Tancred Close, Leamington Spa, Warwickshire, England, CV31 3RZ. We are a company registered in England, with company number 11002571.

CRAYTA provides tools and functionality for the development of videogames and other virtual assets (“Games”). This privacy and data policy (“Privacy Policy”) applies and has effect in respect of the CRAYTA videogames development platform and all related support services, marketplaces, asset libraries, Games, online services, websites, software and products made available by us in connection with CRAYTA (together the "Platform").

If you have any questions or comments about this Privacy Policy, please contact us at legals@unit2games.com

We are committed to protecting and respecting your privacy. The Privacy Policy explains the basis on which personal data we collect from you will be processed by us or on our behalf. Where we decide the purpose or means for which personal data you supply through the Platform or any part thereof is processed, we are the data “controller”. We will comply with all applicable data protection laws, including the General Data Protection Regulation 2016/679 and the (UK) Data Protection Act 2018.

Please read this Privacy Policy carefully as it contains important information about the following:

What information we may collect about you;

How we will use information we collect about you;

Whether we will disclose your details to anyone else; and

Your choices and rights regarding the personal data you have provided to us.

This Privacy Policy should be read in conjunction with our End User License Agreement for CRAYTA.

The Platform may contain hyperlinks to services owned and operated by third parties. These third party services may have their own privacy policies and we recommend that you review them. They will govern the use of personal data that you submit or which is collected by cookies and other tracking technologies whilst using these services. We do not accept any responsibility or liability for the privacy practices of such third party services and your use of these is at your own risk.

We may make changes to this Privacy Policy in future, which will be posted on this page or otherwise made available to you. You should check this page from time to time to ensure you are aware of any changes. Where appropriate we may notify you of changes through the Platform.

2. INFORMATION WE MAY COLLECT ABOUT YOU

We collect and process the following information which may include your personal data:

Information provided by you when using the Platform

(“Basic Information”)

We may collect the following information from you when you use the Platform:

Your Discord user ID;

Your chosen display name for certain parts of the Platform (for example, for your use when publishing a Game you develop on the Platform);

Your user ID (as generated by us); and

Core information ‘events’ and usage activities related to your use of the Platform and/or the Games: including without limitation your use of tools or links on the Platform (for example, how you are using certain development tools to create Games), your gameplay of Games such as your achievement of particular milestones or the occurrence of particular events during your gameplay (for example, completing a tutorial or passing a level).

Contact information provided by you when using our support services

(“Contact Information”)

We may ask you for, or you may submit, certain contact information to us whenever you contact us for support in connection with your use of the Platform.

This may include:

your email address;

your IP address; and

your Discord username.

Information collected for the purposes of providing analytics

(“Analytics”)

We may collect technical information about your use of the Platform and/or Games through the use of tracking technologies and analytics. Personal data we may collect includes the following:

your Discord user ID;

your user ID (as generated by us);

your device operating system & version;

your device make and model;

Game gameplay attempts, progression and results;

Platform tools used and links used;

session game time start, end and duration;

game play frequency;

Virtual item purchase transaction types and spend you have made using virtual items / virtual currency in the Games and/or on the Platform;

the time and date of your first use of the Platform and each Game; and

identification of crashes and defect:

crash and error information; and

IP address.

Information about you collected from third parties

(“Third Party Log In Information”)

Access to the Platform is via a log in through third party media provider Discord; we collect and store personal and non-personal data which is available from Discord, including your Discord user ID, your Discord profile picture or its URL, and the public data of your friends on Discord. We will also receive technical data in order to ensure the Games connect to the correct Discord account./p>

The processing of your personal data by Discord, Inc. for or in connection with Discord, Inc.’s services is subject to Discord, Inc.’s privacy policy (as may be updated from time to time) available at: https://discordapp.com/privacy.

Content created by our users which we host, display and make available

(“User Content”)

When users submit their own User Content to the Platforms (including without limitation when publishing a Game on the Platform or using the Platform to create a Game), this content may contain personal and non-personal data. This could include information in or about the User Content, such as the location of a photo or the date a file was created, or anything else a user decides to communicate using these parts of our Platform.

3. WHY WE COLLECT INFORMATION ABOUT YOU

To provide the Platform to you

We will use information about you (including Basic Information, Analytics, Third Party Log In Information and User Content) for delivering our Platform to you under the End User License Agreement agreed between us. The processing of information in this way is necessary for us to (a) authenticate your account and log in information for your access to the Platform; (b) to record your progress, usage and current status within the Platform and/or within a particular Game; and (c) to ensure the Platform delivers the features promised and functions properly, so that you have the best experience when using the Platform or playing any particular Game.

To help us improve the Platform and fix any problems

We may process information about you (including Basic Information, Analytics, Third Party Log In Information and User Content) so that we can analyse and improve our Platform.

This processing is also necessary for us to pursue our legitimate interests of (i) ensuring that our Platform functions properly so that you and other users have the best experience when playing any Game and using the Platform’s services; (ii) improving the quality of our Platform, and providing a better experience to our users; (iii) identifying and correcting any bugs in the Games and Platform and iv) understanding the effectiveness of our marketing to attract new users and re-engage our current users at an aggregated level.

To help Game developers use the Platform

The Platform provides aggregated and pseudonymised information about you to Game developers for the purposes of Game developers improving upon and developing the Games on the Platform. This information may include, in each case in aggregated and/or pseudonymised form, the Analytics. This processing is necessary for us to pursue our legitimate interests of improving the Platform and understanding how the Games are played.

To respond to your enquiries and requests for support and to enable you to use the Platform

We may process Contact Information so that we are able to properly respond to your enquiries and support requests and so you are able to use the Platform, in accordance with the End User License Agreement agreed between us.

To acquire new users and engage current users

We may process information (including some Analytics) to encourage engagement from our less active users and to notify them with new virtual items or other promotions on offer. We may also process this information to pursue our legitimate interests of acquiring new users for the Platform.

To understand your use of the Platform

We may process information (including Basic Information, User Content and Analytics) to understand how users use our Platform, and to compile statistical reports regarding that activity, as well as understanding how users progress, and their current status within a particular Game. This processing is necessary for us to pursue our legitimate interests of improving the Platform and the offering of the Games.

To prevent fraud and illegal activity

We process personal data for our legitimate interests of ensuring that any use of the Platform is lawful and non-fraudulent, does not disrupt the operation of our services, does not harass our staff or other individuals, to enforce our legal rights and to comply with our legal obligations.

Where we reasonably believe that you are or may be in breach of any applicable laws or our End User License Agreement, we may use your personal data to inform relevant third parties such as your law enforcement agencies about the content.

We reserve the right to disclose your identity to any third party who is claiming that any User Content posted or published by you constitutes a violation of their intellectual property rights, or of their right to privacy.

4. DATA SHARING

We will share your information with third parties only in the ways that are described in this Privacy Policy

Group members, personnel, suppliers or subcontractors: We keep your information confidential, but may disclose it to any member of our group (which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006), our personnel, suppliers or subcontractors insofar as it is reasonably necessary for the purposes set out in this Privacy Policy. However, this is on the basis that they do not make independent use of the information, and have agreed to safeguard it.

Merger or acquisition: If we are involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via, account message and/or a prominent notice on our website of any change in ownership or uses of this information, as well as any choices you may have regarding this information.

Required by law: In addition, we may disclose your information to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).

Enforcement: We may also disclose your personal data to third parties in order to enforce or apply the terms of agreements, to investigate potential breaches, or to protect the rights, property or safety of Unit 2 Games, our customers, or others.

Game developers: We share certain information about you with Game developers on our Platform as further detailed in clause 3 above.

5. YOUR RIGHTS IN RELATION TO PERSONAL DATA WHICH WE PROCESS RELATING TO YOU

You have rights over the way we process personal data relating to you, as set out in the table below. We aim to comply without undue delay, and within one month at the latest, in the event of receipt of a request from you in relation to your personal data. To make a request, you can send an email to legals@unit2games.com.

Ask for a copy of data we are processing about you and have inaccuracies corrected

You have the right to request a copy of the personal data we hold about you and to have any inaccuracies corrected.

We will use reasonable efforts to the extent required by law to supply, correct or delete personal data held about you on our files (and with any third parties to whom it has been disclosed to).

Object to us processing data about you

You can ask us to restrict, stop processing, or to delete your personal data if:

you consented to our processing the personal data, and have withdrawn that consent;

we no longer need to process that personal data for the reason it was collected;

we are processing that personal data because it is in the public interest or it is in order to pursue a legitimate interest of Unit 2 Games or a third party, you don’t agree with that processing, and there is no overriding legitimate interest for us to continue processing it;

the personal data was unlawfully processed;

you need the personal data to be deleted in order to comply with legal obligations;

the personal data is processed in relation to the offer of a service to a child.

Obtain a machine readable copy of your personal data, which you can use with another service provider

If we are processing data in order to perform our obligations to you, or because you consented, if that processing is carried out by automated means, we will help you to move, copy or transfer your personal data to other IT systems.

If you request, we will supply you with the relevant personal data in CSV format. Where it is technically feasible, you can ask us to send this information directly to another IT system provider if you prefer.

Make a complaint to a Supervisory Authority

If you are unhappy with the way we are processing your personal data, please let us know by contacting us via the support services.

If you do not agree with the way we have processed your data or responded to your concerns, an alternative is to submit a complaint to a Data Protection Supervisory Authority.

6. DATA RETENTION

We will hold your personal data on our systems for as long as is necessary for the relevant service, or as otherwise described in this Privacy Policy.

7. CHILDREN

We do not use our Platform to knowingly solicit information from or market to children under the age of 13. Our End User License Agreement prohibits users aged under 13 years from accessing our Platform. In the event that we learn that we have collected personal data from a child under 13 years of age we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13 years of age please contact us at legals@unit2games.com.

8. SECURITY

We will take all reasonable technical and organisational precautions to prevent the loss misuse or alteration of your personal data. For example, our databases are password protected and limited to essential employees only (such as Unit 2 Games’ management or employees whose main role requires system access).

Please be aware that, although we endeavour to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.

9. CONTACT DETAILS

All questions, comments or enquiries should be directed to Unit 2 Games at legals@unit2games.com. We will endeavour to respond to any query or questions within three business days.